Manitoba Women’s Enterprise Centre Inc. (“WECM”)
WECM’s Privacy Code informs you of our commitment to privacy. It tells you the ways we ensure that your privacy and the confidentiality of your information are protected.
The objective of WECM’s Privacy Code is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada) and other applicable privacy legislation.
WECM will conduct periodic reviews of this Privacy Code to make sure that it remains current with changing standards, technologies and laws.
Table of Contents
- Compliance with Legal and Industry Standards
- WECM’s Privacy Code
- Purposes for the Collection, Use, Retention and Disclosure of Information About You
- Key Principles
- Information Regarding Website Practices
- Updating This Code
Compliance with Legal and Industry Standards
We will make every reasonable effort to comply with industry standards and applicable federal and provincial laws in Canada, including the Personal Information Protection and Electronic Documents Act.
WECM’s Privacy Code
WECM’s Privacy Code only applies to identifiable individuals whose personal information WECM collects, uses, retains and discloses in the course of commercial activities. When we use the words “personal information” or “information” in this Privacy Code, we mean information about an identifiable individual, with the exception of the name, title or business address or telephone number of an employee of an organization, which is public information. Further, these terms do not include information that does not identify particular individuals, like aggregate statistics or anonymous data, or information which is publicly available, as specified in applicable laws.
Purposes for the Collection, Use, Retention and Disclosure of Information About You
The following are our purposes for collecting, using, retaining and disclosing personal information:
- To establish and maintain a relationship with you as a client and to provide services to you;
- To provide you with information about products, programs, services, training resources and upcoming events that we believe may interest you;
- To administer our services, to assess the quality and quantity of our services, conferences, to maintain adequate accounting and tax records, and to have information in such form as we may reasonably require for our business needs;
- To meet legal, regulatory and governmental requirements (including, for example, the requirements of Western Economic Diversification Canada (“WD”) as our primary funder), to detect and prevent fraud and to protect the interests of you, WECM and WD; and
- To achieve any other purpose to which you have given your consent.
For our clients who do not have loans with WECM, our purposes differ in that we are not required to maintain accounting and tax records related to such individuals. For our loan clients, further details regarding our additional purposes are outlined in your Loan Application Form and/or Loan Agreement with WECM.
WECM’s Privacy Code consists of the following key principles, which apply to all aspects of our handling an individual’s personal information in the context of a commercial activity, including the collection, use, retention and disclosure of such information.
A. Collecting and Using Information
We collect and use information to establish and serve you as our client.
We gather and use your personal information to provide you with the services you have requested. We collect, use, retain and disclose information about you only with your consent, except as outlined in this Privacy Code. In obtaining your consent, whether express or implied, our purposes for which we require your information are outlined above. If our purposes differ than those outlined above, we will advise you of our new purposes at the time of collection of your information.
We may depart from this consent principle in accordance with the limited exceptions described in this Privacy Code, when permitted by other written and posted policies established by WECM, or where required or permitted by applicable laws (for instance, we may disclose personal information in an emergency to protect human life or safety).
The nature and amount of information we collect depends on the service you have requested. For every client, we need your contact information (your name, address and some identification). For loan clients, we require more information than we require from our other business clients. Here is why we need some of the other information we may ask a client to provide.
This helps us identify you and ensure that no one is trying to impersonate you.
Social Insurance Number (SIN)
We use your SIN to keep your information separate from that of other clients with a similar name and for loan applicants, to obtain information with your consent, through the credit approval process.
For loan applicants, your financial information is used to assess your eligibility for a business loan.
For loan applicants, we require this if you wish to apply for group creditor life insurance as the insurance company will not provide such coverage unless you are eligible based on your health information.
We only collect the information we need and only use it for the purposes explained to you.
We will only ask for the information we need for the particular service you requested and only use it for the purposes outlined in this Privacy Code or, if applicable, outlined to you at the time of collection of your information, such as in the case of a loan applicant. When you apply for a new service, we will indicate how we intend to use your information if our purposes differ from those already outlined. We will advise which information would help us to serve you but is optional for you to provide.
With your consent, we may obtain information about you from third parties.
Obtaining additional information about you from trustworthy third parties helps us assess your eligibility for our services. For example, for loan applicants we need to know your credit history. For this reason, we may contact other lenders or credit bureaus to give us information on your credit history. We may also contact employers or other personal references to verify information that you have given us. We will not do this without your consent, but please remember that if you do not give your consent we will not be able to process your loan application and extend credit services to you.
B. Releasing Information
Under no circumstances do we sell client lists or information to others. We release your information to parties outside WECM only under the following circumstances:
Where we have your consent, whether express or implied.
For example, for loan applicants we will disclose your credit history with us to other lenders or credit bureaus in order to support the credit approval process. In such cases, we release the information required to identify you, as well as facts from our credit records about your repayment history.
To our suppliers and agents who assist us in servicing you and whom we can reasonably trust to respect your privacy.
For example, we will disclose your name and address to a courier company making a delivery to you at our request. In such cases, we only make disclosure to the extent necessary and whenever possible, require that the party receiving this information provides reasonable assurances that they will respect the privacy of your information in accordance with applicable laws.
When required or permitted by law to do so.
For example, we must give information in response to a valid demand, search warrant or other legally valid enquiry or order. We may disclose information to the authorities to serve a clear public interest and fulfill our public duty – such as to protect against fraud or other criminal activity. We may take action to protect the interests of WECM which may result in disclosing information to parties outside WECM, such as using agents to collect overdue accounts. We also may disclose information under an exception to the requirement for consent expressly set out in applicable laws, such as the exception for disclosures necessary to protect human life or safety in an emergency.
When we need to do so to protect our interests in the context of an existing or potential legal or administrative proceeding.
For example, in the event of a proceeding commenced by or against us in connection with you, we may disclose your information to our lawyers and to the court or administrative body involved.
C. Protecting Information
We will protect your information with appropriate safeguards and security measures.
We have reasonable security standards to protect our systems and your information against unauthorized access and use. All employees of WECM are familiar with the procedures that must be taken to safeguard client information. We retain your information only as long as it is legally or reasonably required by us.
The length of time we retain information varies depending on the service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is legally or reasonably required by us. When your information is no longer needed, we have procedures to destroy, delete, erase or convert it to an anonymous form.
D. Providing Information Access and Accuracy
We will give you access to the information we have about you.
Most of your information is kept in our client file about you. Please contact our Privacy Officer if you wish to access any information we may have about you. We will advise you in advance if a minimal charge will be required for conducting a search, and will do our utmost to respond to your request within 30 days. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to WECM, is too costly to retrieve, or cannot be disclosed for other legal reasons.
We will make every reasonable effort to keep your information accurate and up-to-date.
Having accurate information about you enables us to give you the best possible service. You can help by keeping us informed of any changes, for instance if you move or change telephone numbers. If you find any errors in our information about you, please send us the correction in writing by mail, fax or e-mail. We will make appropriate corrections immediately and make sure that such corrections are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.
E. Respecting and Responding to Your Privacy Concerns
We will explain your options of refusing or withdrawing consent to the collection, use or disclosure of your information, and we will record and respect your choices subject to any legal or contractual restrictions and reasonable notice.
Please contact our Privacy Officer if you have any questions related to your options. For example, you may refuse consent for WECM to do a credit check, but we will not be able to extend credit services to you. Once you have a credit product, you will not be able to withdraw your consent to share your credit experience with other lenders and credit bureaus, as this is necessary to support the credit approval process.
We will investigate and respond to your concerns about any aspect of our handling your information.
If you have any concerns or questions about privacy and confidentiality – or any concerns about the way a request for information was handled – you can take the following action.
Contact WECM’s Privacy Officer:
Our Chief Executive Officer
Phone (204) 988-1860 or 1 (800) 203-2343
Fax (204) 988-1871
Our Privacy Officer has the decision-making authority to resolve most concerns. However, if you are unsatisfied with the way your complaint or request was addressed, you may contact the federal privacy commissioner:
Office of the Privacy Commissioner
112 Kent Street